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Who Applied? When
Will We Know? +++++++++++++++++++++++++++++++++++++++++++++++++++ Here is the Opportunity "Full power" offers up to 100kw power and coverage that LPFM operators dream about. Unfortunately few if any LPFM organizaions have the deep pockets to complete with large NCE broadcasters including state-wide governmental networks. There will be no free FCC "Channel Finder". CCB encourages as many LPFM groups as possible to file knowing that a 100kw station could cost $500,000 - or more if the organization choses to build its own 500 foot tower. Cost of engineering / legal battles were probably greater than the total expense in building most LPFM stations. On the good side, some uncontested applications will be granted without a battle. Here
is what the FCC just did. (Section 204 announces the October window): A preliminary engineering study to see if a frequency is available is $300. The total cost of a single-location filing is normally $2,500. If you are a LPFM licensee that confirmed prior to the LPFM windows that there were no primary channels available in your area, and LPFM was your only true option – then this news will be no real news for you. Yes, some things do change in the database where that option may need to be explored again – and we’d be happy to help. However, if you are a LPFM station owner, and the channel you reside on, or another non-commercial channel is available in the area that would allow for an application to be filed and a Construction Permit granted, we recommend that you take advantage of this opportunity. You, as a LPFM licensee, CP holder, or
applicant are ineligible to own both a LPFM and any other broadcast media, such
as a full power FM. However, you can apply for the full power, and if granted
return your LP license or request the LP CP or LP application be dismissed. If
you hold a LP license you can also request transfer to another local nonprofit
and save your LP station at the same time. In some cases it would be a shame
for a LP owner to not take advantage of this great opportunity to
“upgrade”. Just to restate, filing an application for a new non-commercial
FM primary station does not breach any FCC rule just because you are a LPFM
licensee, CP holder, board member, applicant, etc., but you will have to give
up one or the other, Full Power FM or LP. Why would you be willing to give up your LPFM? Especially if it’s for a Class A 100 watt station? There are a number of reasons, the first being coverage, a class A can be at 328’ HAAT while a LP can only be 100’ HAAT. That’s more than 3 times the height available and the coverage is greatly improved. Another reason is contour protection for Class A’s while LPFM’s are required to meet only distance separation. An example here would be that a Class A station will not have anything allowed within it’s protected contours. Within the protected contours a Class A is interference free. On the other hand, a LPFM must be 67 km’s from a co-channel Class A to meet distance separation and is still allowed to receive whatever interference exists. We know interference has been a serious problem to the limited coverage of many LPFM stations. Under the current LPFM rules is the secondary status
nature of LPFM’s. Despite the fact that the FCC claims only one LPFM has been
displaced by a primary and forced off the air, the true number is higher. As a
secondary service any antenna change, site changes, or purchases and
reshuffling of primaries that could happen, can result in you receiving a
letter from the Commission to shut down. The filing window for these new
FM stations is for the reserved educational FM band (lower fifth of the FM
band), frequencies 88.1 to 91.9. These aren’t limited to lower powers and
small local only coverage areas. These stations can be up to 100,000 watts,
which is the legal limit the FCC allows for any FM station. In most parts of
the country there isn’t a lot of room on the FM band for 100,000 watts anymore,
the band is just too congested, and new station power will be closer to 6,000
watts. There will be many large cities and parts of the country where there are no more available channels. As an example, you should rule out locations like New York City, Baltimore, DC, most of the New England States, most of Florida, the Atlantic and Pacific coastlines, Atlanta, Dallas, Detroit, Denver, Chicago, Kansas City, Los Angeles, San Francisco, etc. Most of the big cities have received as many stations as
allowed, and any more would cause unacceptable interference to exist. If you
are in an area you suspect to be one of those congested locations, don’t
despair, just contact us and we will provide you with an educated, honest
appraisal and share what we know about your location already, without any
charge. The FCC receives, processes and licenses work based on the applications filed, but they do not assist in preparing the required engineering and other information needed in an application. There is no Channel Finder for Full Service stations on the FCC’s website as there was for LPFM unfortunately. And, it is not as simple a process as pushing some buttons, rather it requires careful measurements, tower and property availability studies, TV 6 compliance (where applicable), IF Channels, and omni or directional antenna design. Time is required to do the work properly and you’ll need time to consider your options after receiving the results and making the best decision on how to proceed. You will receive the completed report, which includes a technical and detailed analysis, summary, and all maps required to completely explain the findings. After this you’ll need to confirm a working transmitter/antenna site, whether property or an existing tower. If you are a LPFM owner, we understand the financial burden
involved in your meeting day to day expenses and we know your budget can be
tight. We will prepare and submit your FCC Form 340 application for $2,500 –
guaranteed “accepted for filing” by the Commission. In many locations
throughout the country, your application must also consider a TV 6 station.
Where we must protect TV 6 or request a TV 6 waiver, we will need to complete
those applications for additional labor on a case by case basis. The new method of filing for a Full Power Non-Commercial FM
is much superior to the previous method of filing an application “as
needed”. In the past, applications were filed, and added to the database,
then any other non-profit group might file a competing application for the same
channel. Often it occurred that the competing application simply copied the
engineering and technical section of the initial application. This resulted in
a serious bottleneck of FCC resources to process legitimate applications. As
well, blackmailing the original applicant for money so that applicants of
fraudulent applications would file dismissals seemed to be an obvious tactic
some were practicing. These problems have been resolved with the new filing
windows. Now, during a 5 or 10 day filing window period, an applicant will file
an application for a channel to serve a location, and no one other than the
applicant will have this information available to them. Once the filing window is closed, and no other applications being received, a list of singleton applications will be prepared by the Commission. A “singleton” is an application with no overlaps created by others during the filing window, and can result in a Construction Permit in a matter of a few months. For those that are “MX’d” (Mutually Exclusive) applications, they inadvertently have a competitor where some type of prohibited overlap has come about by the filing of new applications. These will be resolved by the Commission on a population served tally comparison, and where the pop tally is not conclusive, then the Commission will resort to a points basis – usually based on a set of 4 questions & tie breakers. The questions are as follows: 1. Established Local Applicant (Who is local and
existed the greater length of time) As to the cost of a Full Power Non-Commercial FM station,
this is hard to nail down initially. Most full power stations that will be
applied for during the next filing window will be between 100-6,000 watts. This
power range is classified as a Class A station. Full Power
FM Non-Commercial stations can broadcast up to 100,000 watts, but not many
locations across the United States have such openings any longer. So in the
case of a Class A 100w- 6,000w station the cost could run as inexpensively as a
nicely equipped LPFM station, or could run into hundreds of thousands of
dollars where a large transmitter, new tower and multi bay directional antenna
is required. The question of cost can’t really be estimated until after the
Frequency Search is completed. |
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